Germany e-invoicing 2027: Federal Ministry of Finance issues third supplementary letter on the mandatory E-Rechnung

The Hague, 26 October 2026. The German Federal Ministry of Finance (BMF) has published a third supplementary letter (BMF-Schreiben) on the mandatory e-invoice (E-Rechnung), dated 15 October 2026, reference III C 5 – S 7287-a/00019/021/017. For Germany e-invoicing 2027, it is the reference document for software vendors: it sets out when a validation error has tax consequences, how corrections and final invoices are structured, and which transition rules apply around 1 January 2027.

What the BMF letter covers

The letter supplements those of 15 October 2024 and 15 October 2025 and consolidates answers from unpublished letters dated 23 February, 2 July, 21 July and 1 September 2026. The VAT Application Decree (UStAE) is being amended accordingly.

Validation is not a condition of validity

The BMF treats validation as a tool for demonstrating formal compliance, not a legal condition of validity. A file that breaches an EN 16931 business rule does not automatically stop being an e-invoice for VAT purposes. Only errors in the mandatory VAT details under Section 14(4) and Section 14a of the German VAT Act (UStG) have tax consequences, including for input VAT deduction. The BMF will not provide an official validator and does not recommend tools.

Mandatory details and mapping

All mandatory details belong in the structured part. For assigning them to business terms (BT) and business groups (BG), the BMF points to the KoSIT and FeRD mapping tables. A mere reference to a contract or an unstructured attachment is not enough; supporting detail, such as timesheets, may go in an embedded attachment.

Corrections, construction, gross-price and final invoices

• Corrections: where the e-invoicing obligation applies, the correction must also be an e-invoice. Replacement, cumulative correction and credit note are all possible; the technical invoice type code is not yet finally settled. Hand-written strike-throughs (the Rotstift method) are only permitted on an other invoice (sonstige Rechnung, any invoice that is not an e-invoice). A self-billed credit note (Gutschrift) is allowed if agreed and the original invoice is referenced (Section 31(5) UStDV).
• Construction invoices: the structured part may show only totals per trade (Gewerk) if a readable embedded attachment contains the breakdown and is clearly referenced. A GAEB file may be added.
• Gross-price invoices: for EN 16931 invoices based on gross prices issued up to 31 December 2027, totals per tax rate or exemption may replace line items, with details in an attachment.
• Final invoices: until 30 June 2030, partial payments already received may be deducted as a total in BT-113 (Paid amount), with the details in BT-22 (Invoice note) or in an embedded attachment. The 2024 letter allowed this only until 31 December 2027.

Issuing obligation, public sector and penalties

The issuing obligation applies only where the customer is a business. In mass-market business, establishing customer status when a contract starts or changes is sufficient. Issuing an other invoice where an e-invoice is required is not an administrative offence under Section 26a(2) No. 1 UStG, although the invoice remains non-compliant. Public authorities acting as businesses follow the same rules, and notices of public-law charges issued until 30 June 2030 may take the form of an other invoice.

Transition rules for Germany e-invoicing 2027

Receiving e-invoices has been mandatory for businesses in Germany since 1 January 2025. For issuing, Section 27(38) UStG applies: supplies made up to and including 31 December 2026 may still be invoiced with an other invoice. Businesses whose total turnover in 2026 does not exceed EUR 800,000 may continue to do so until 31 December 2027. Small-amount invoices up to EUR 250 and travel tickets remain outside the obligation.

The letter applies to all supplies made after 31 December 2024. E-invoices issued up to and including 31 December 2026 that comply with the earlier letters but not with this one will not be challenged. Technically, the issuing obligation starts on XRechnung 3.0 and ZUGFeRD; the preliminary version of XRechnung 4.0 is not required for it. In the longer term, the BMF is working towards a reporting system for invoice data from 1 July 2030.

What it means and what to do now

Software vendors: product checklist before 1 January 2027

1. Classify validation errors. Separate VAT-relevant errors (Section 14(4) and Section 14a UStG) from technical business-rule errors, and show the distinction to users. Do not let the receiving side automatically reject every technical error.
2. Map according to KoSIT and FeRD. Follow the current mapping tables and make sure no mandatory detail exists only in an attachment or the PDF view.
3. Build corrections as e-invoices. Support replacement, cumulative correction and credit notes referencing the original invoice, and keep the invoice type code configurable. Block manual strike-throughs.
4. Support BT-113 and BT-22 for final invoices with partial payments received, plus the embedded-attachment variant.
5. Offer a construction mode: trades with totals, an embedded attachment with the breakdown, and optional GAEB.
6. Provide a gross-price mode with totals per tax rate, ending on 31 December 2027.
7. Record customer status at onboarding and on contract changes, so the correct invoice type is selected automatically.
8. Make the transition rule configurable per customer: customers with 2026 turnover of EUR 800,000 or less must still be able to send an other invoice until 31 December 2027.

Businesses

If your business falls under the German domestic B2B obligation, ask your software vendor about the points above. Your 2026 turnover determines whether you must issue e-invoices from 1 January 2027 or from 1 January 2028.

Integrators and Peppol service providers

Integrators should update mappings and validation profiles so reports flag VAT-relevant errors separately. Peppol service providers carrying XRechnung or ZUGFeRD should separate business-rule errors from errors in mandatory details and pass embedded attachments through unchanged.

Sources

1. Federal Ministry of Finance (BMF): letter of 15 October 2026, III C 5 – S 7287-a/00019/021/017 (PDF, primary source, in German)
2. Haufe: BMF, ergänzende Regelungen zur E-Rechnung (in German)
3. Ebner Stolz: Drittes BMF-Schreiben zur E-Rechnung (in German)
4. PwC Steuern und Recht: BMF, ergänzende Regelungen zur elektronischen Rechnung (in German)
5. Kleeberg: E-Rechnung, neues BMF-Schreiben vom 15.10.2026 (in German)
6. Ecovis KSO: E-Rechnung 2027, neues BMF-Schreiben (in German)
7. SAP E-Invoice: German e-invoicing BMF guidance October 2026
8. Peppol.now: XRechnung 4.0 preliminary version
9. Peppol.now: Germany e-reporting from 1 July 2030

Looking for software that supports Germany e-invoicing 2027, with XRechnung, ZUGFeRD and Peppol? The Peppol.now comparison tool lets you filter providers by region, software category and features.